This is a corporate policy document designed to meet the standards of the Foreign Corrupt Practices Act, a provision of the Securities and Exchange Act of 1934. FCPA generally prohibits payments by companies and their representatives to foreign (i.e., non-U.S.) government and quasi-government officials to secure business.
The Oregon Foreign Corrupt Practices Act (CPA) is a corporate policy that establishes guidelines and regulations to prevent bribery and corrupt business practices in international transactions involving Oregon-based companies. This Act, which is in alignment with the federal CPA, aims to promote fair competition, integrity, and ethical behavior by organizations operating in Oregon. By complying with the Oregon CPA, companies demonstrate their commitment to conducting business with integrity and upholding the reputation of the state. Key components of the Oregon CPA include: 1. Prohibition of bribery: The Oregon CPA strictly prohibits companies from offering, giving, promising, or authorizing any type of bribe, kickback, or corrupt payment to foreign officials, political parties, or candidates. This includes both monetary and non-monetary benefits. 2. Third-party due diligence: The Act requires companies to conduct thorough due diligence on business partners, agents, consultants, and intermediaries before engaging in any transactions with them. This is to ensure that these parties do not engage in corrupt or illegal activities on behalf of the company. 3. Books and records: Oregon CPA policies emphasize the importance of maintaining accurate and transparent records of all transactions, expenses, and financial statements related to international business. These records should be in compliance with the Generally Accepted Accounting Principles (GAAP) and must not involve any illegal activity. 4. Internal controls: Companies are required to establish and maintain robust internal controls to prevent and detect illegal activities, including bribery and corruption. An effective internal control system helps ensure compliance with the Oregon CPA, identifies potential risks, and establishes procedures to mitigate those risks. 5. Training and awareness: It is crucial for companies to provide regular training to employees, executives, and third parties about the provisions and implications of the Oregon CPA. Increasing awareness helps prevent inadvertent violations and encourages a culture of integrity and ethical behavior within the organization. Different types of Oregon CPA corporate policies may vary depending on the size, industry, and international footprint of the organization. Some companies may have a standalone policy solely dedicated to the Oregon CPA, while others may incorporate it into their broader ethics and compliance policies. The policy may also differ based on the specific business operations, risks associated with particular countries or regions, and the level of due diligence required for different types of business relationships or transactions. Overall, the Oregon CPA — Corporate Policy plays a vital role in guiding organizations to conduct business ethically, minimize legal risks, and maintain a strong reputation both locally and globally.
